Services
Election strategy
FEIE versus FTC modeling
Year-by-year comparison of foreign earned income exclusion versus foreign tax credit positions, with attention to the long-term consequences.
Remediation
Non-compliance
Streamlined Filing Compliance Procedures (SFCP) for taxpayers whose failure to report foreign assets or income was non-willful (due to mistake, or misunderstanding of the law rather than intentional evasion).
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Delinquent International Information Return Submission Procedures for taxpayers who failed to file required international forms (Form 5471 or 3520) but whose income was otherwise properly reported.
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Voluntary Disclosure Practice: Designed for taxpayers with willful non-compliance or those worried about potential criminal liability.
Entity structure
Formation and modeling
How you set up your business affects how much tax you pay now, when you take money out, and when you eventually sell or close. We'll walk you through how C corporations, S corporations and partnerships are taxed. If you've formed an LLC, we'll also explain your choices: it can be taxed as a sole proprietorship, a partnership, an S corporation or a C corporation, and each choice changes your tax results. We look at the whole picture, not just the tax bill.
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Tax planning
Proactive, year-round tax strategy
Coordinated with how your portfolio is managed - capital gains budgeting, Roth-conversion timing, asset location, and equity compensation planning. Built for high-income complexity: concentrated stock, RSUs/ISOs, K-1s, and multi-state income.
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Pre-arrival planning for foreign nationals - basis step-up considerations, pre-immigration trust review, deferred compensation, treaty analysis, and the elections that must be made before the substantial presence threshold is crossed.
Exit tax
Expatriation and the §877A regime
Covered expatriate analysis, mark-to-market tax calculations and planning, deferred compensation and specified tax-deferred account treatment, and the timing decisions that materially change the tax on relinquishing lawful permanent residence/renouncing citizenship.
Estate and gift
Tax Planning
Effective estate and gift tax planning centers on maximizing the Federal annual exclusion and leveraging the unified lifetime exemption limit of $15 million per individual ($30 million for married couples) taxed at a top marginal rate of 40%.